Privacy Policy
DATE:
Effective starting 23rd April 2024
1. INTRODUCTION AND SCOPE
1.1. This Privacy Policy ("Policy") explains how Legacy Labs Private Limited ("Living Legacy", "we", "our", or "us") collects, uses, and protects the personal data of individuals ("you" or "users") who access or use the Living Legacy platform, website, digital applications, or any services provided by Living Legacy (collectively, the "Service").
1.2. By accessing or using the Service, you agree to the collection, use, and disclosure of your personal data as described in this Policy. If you do not agree with the terms of this Policy, please refrain from using the Service.
1.3. This Policy is incorporated into and forms part of the Living Legacy Terms and Conditions ("Terms"), which govern your use of the Service. Any capitalised terms not defined in this Policy shall have the meanings ascribed to them in the Terms.
1.4. The Service is operated and provided within the sovereign territory of Singapore. If you are accessing or using the Service from other jurisdictions, you are responsible for complying with the local laws and regulations applicable to your particular jurisdiction.
1.5. We may revise this Policy from time to time by updating this page. You should revisit this page periodically to ensure that you are aware of any changes, as your continued use of the Service will constitute your acceptance of the revised Policy.
2. DATA COLLECTION AND USAGE
2.1. Living Legacy collects and processes various types of personal data from you in order to provide the Service and for related purposes. The types of personal data we collect may include:
2.1.1. Personal Identifiers:
Such as your name, contact details (e.g., phone number, email address), date of birth, and other identifiers.
2.1.2. User Content:
Any text, images, audio, video, or other content that you upload, submit, or otherwise provide through the Service.
2.1.3. Usage Data:
Information about how you use and interact with the Service, including device information, access logs, and usage patterns.
2.1.4. Location Data:
While we do not currently collect location data, Living Legacy reserves the right to collect and process information about your location when using the Service if needed to aid in furthering or improving the Service.
2.2 We collect and process your personal data for the following purposes:
2.2.1. Creating and Maintaining Digital Replicas: To create and maintain personalised digital replicas or avatars that represent you or your loved ones within the Service.
2.2.2. Providing, Improving, and Customising the Service: To provide, improve, and customise the Service according to your preferences and usage patterns, as well as to develop new features and functionalities.
2.2.3. Creating Digital Companions and Enabling Upskilling/Reskilling: With the end intention of creating digital companions and boosting reskilling and upskilling initiatives as the product evolves.
2.2.4. Communication and Customer Support: To communicate with you about the Service, respond to your inquiries, and provide customer support.
2.2.5. Service Analytics and Security: To analyse and enhance the Service's functionality, performance, and security, as well as to detect and prevent any potential misuse or abuse.
2.2.6. Legal Compliance and Enforcement: To comply with applicable laws, regulations, and legal obligations, as well as to enforce our Terms and Conditions and protect our rights and property.
3. DATA SHARING AND DISCLOSURE
3.1. Living Legacy does not sell, rent, or share your personal data with third parties for their direct marketing purposes without your explicit consent.
3.2. However, we may share your personal data with trusted third-party service providers who assist us in operating, maintaining, and improving the Service. These third-party service providers are obligated to maintain the confidentiality and security of your personal data and are prohibited from using it for any purpose other than the services they are providing to Living Legacy.
3.3. We may also disclose your personal data in the following circumstances:
3.3.1. Legal Compliance:
If required to do so by law or in response to valid requests from public authorities (e.g., court orders, subpoenas, or other legal processes).
3.3.2. Protection of Rights and Safety:
To protect the rights, property, or safety of Living Legacy, our users, or others, including to investigate and prevent any actual or suspected illegal activities or violations of our Terms and Conditions.
3.3.3. Business Transfers:
In the event of a corporate transaction, such as a merger, acquisition, reorganisation, or sale of assets, your personal data may be transferred as part of that transaction. In such cases, we will ensure that the acquiring entity continues to comply with the terms of this Privacy Policy.
3.4. We may also disclose your personal data in the following circumstances:
3.4.1. With Your Consent: We may share your personal data with third parties if we have obtained your explicit consent to do so.
3.5. Living Legacy takes reasonable steps to ensure that third parties who may receive your personal data are obligated to protect and process it in accordance with the principles and requirements of applicable data protection laws and regulations. However, we cannot guarantee the privacy practices of such third parties.
4. DATA SECURITY
4.1. Living Legacy implements reasonable technical and organisational measures to protect the personal data of our users from unauthorised access, alteration, disclosure, or destruction.
4.2. We store user data, including User Content such as images, audio, and videos, in encrypted format on secure servers. Data in transit is also encrypted using industry-standard protocols.
4.3. Additionally, we employ various security measures, including:
4.3.1. Secure access controls and authentication mechanisms
4.3.2. Regular security audits and vulnerability testing
4.3.3. Firewalls and intrusion detection systems
4.4. However, no method of data transmission or storage is completely secure, and Living Legacy cannot guarantee the absolute security of your personal data. While we take all reasonable precautions to protect your data, we cannot be held responsible for any unauthorised access, alteration, disclosure, or destruction of data that may occur through no fault of our own.
4.5. We encourage you to take appropriate measures to protect your personal information, such as maintaining the confidentiality of your login credentials and implementing robust security practices on your devices.
5. DATA RETENTION AND DELETION
5.1. At Living Legacy, we retain your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy's "Data Collection and Usage" section, unless a longer retention period is required or permitted by law.
5.2. The criteria used to determine our retention periods include:
5.2.1. Legal obligations: We may retain certain data to comply with applicable laws, regulations, legal processes, or enforceable governmental requests.
5.2.2. Business operational needs: Data may be retained as long as necessary to provide you with the Service, manage your account, resolve disputes, and enforce our agreements.
5.2.3. User instructions: We may retain data in accordance with your instructions, such as when you request us to keep certain information for a specific purpose.
5.3. Users can request the deletion or removal of their personal data from Living Legacy's systems by submitting an email request to our customer support team at general@livinglegacy.sg. We will respond to all verified deletion requests within 30 days and make reasonable efforts to delete or anonymize your personal data from our active systems.
5.4. However, please note that we may be unable to delete or modify certain data contained in digital replicas or avatars created through the Service, as that data may be intrinsically linked to the core functionality of those features. Additionally, some data may remain in backup or archived records as required by applicable laws or our data retention policies.
5.5. If you have any questions or concerns about our data retention or deletion practices, please contact us at general@livinglegacy.sg.
5.6. We encourage you to regularly review and update your personal information to ensure its accuracy. You have the right to access, correct, or request the deletion of your personal data in accordance with applicable data protection laws.
6. USER RIGHTS AND CHOICES
6.1. Living Legacy respects your rights and provides you with choices regarding your personal data. Depending on the applicable laws and regulations, you may have the following rights:
6.1.1. Access:
You have the right to access the personal data we hold about you and obtain a copy of that data.
6.1.2. Rectification:
If any of the personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected.
6.1.3. Erasure:
In certain circumstances, you have the right to request that we erase your personal data from our systems.
6.1.4. Restriction:
You may have the right to request that we restrict the processing of your personal data in specific situations.
6.1.5. Portability:
Where applicable, you may have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format.
6.1.6. Objection:
You have the right to object to the processing of your personal data in certain circumstances.
6.2. To exercise any of these rights, please submit your request by email to general@livinglegacy.sg with detailed information about your request. We will respond to all verified requests within a reasonable timeframe and in accordance with applicable data protection laws.
6.3. Please note that while we will make reasonable efforts to fulfil your request, there may be instances where we cannot delete or modify certain personal data contained in digital replicas or avatars created through the Service, as that data may be intrinsically linked to the core functionality of those features. Additionally, any text information you provide through the Service may be used as training data for our systems and may not be removable.
6.4. You can update or modify certain personal data directly through the Living Legacy web application or by contacting our customer support team. We encourage you to keep your personal information accurate and up-to-date at all times.
6.5. If you have any questions or concerns about your rights or choices regarding your personal data, please contact us at general@livinglegacy.sg.
7. THIRD-PARTY SERVICE LINKS
7.1. The Living Legacy Service may integrate with or contain links to third-party websites, services, and applications ("Third-Party Services") that are not owned or controlled by Living Legacy. Examples of such Third-Party Services include social media platforms, cloud storage providers, or other tools and technologies that may be incorporated into or accessible through our Service.
7.2. Living Legacy does not have control over the privacy practices, content, or operations of these Third-Party Services. Any personal data you provide or activities you engage in while using these Third-Party Services will be subject to their respective privacy policies and terms of use, not this Privacy Policy.
7.3. We strongly advise you to review the privacy policies and terms of any Third-Party Services before using them or providing any personal data. Living Legacy is not responsible for the privacy practices or the content of such Third-Party Services.
7.4. Certain Third-Party Services may allow you to authenticate or log in using your Living Legacy account credentials. By enabling this integration, you authorise Living Legacy to share certain account information and data with the Third-Party Service as necessary to facilitate the integration.
7.5. The inclusion of a link to a Third-Party Service on the Living Legacy platform does not imply our endorsement of the Third-Party Service or any association with its operators. We reserve the right to modify, disable, or discontinue integration with any Third-Party Services at any time without prior notice.
7.6. If you have any concerns about the privacy practices of Third-Party Services, please contact the respective service providers directly.
8. UPDATES AND CHANGES TO PRIVACY POLICY
8.1. Living Legacy reserves the right to modify or update this Privacy Policy at any time. We will reflect any material changes to our data practices through updates to this Policy.
8.2. If any updates constitute a material change, we will notify you by reasonable means, such as by posting a prominent notice on our website or sending a direct notification to the email address associated with your Living Legacy account.
8.3. Your continued use of the Living Legacy Service after the effective date of any updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree with the terms of the updated Policy, you should discontinue your use of the Service.
8.4. We encourage you to periodically review this Privacy Policy for any changes. The "Last Updated" date at the top of this document indicates when the latest modifications were made.
9. CONTACT INFORMATION
9.1. If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer at:
Email: general@livinglegacy.sg
9.2. We will make reasonable efforts to respond to your inquiries and address your concerns in a timely manner.
Effective starting 23rd April 2024
1. INTRODUCTION AND SCOPE
1.1. This Privacy Policy ("Policy") explains how Legacy Labs Private Limited ("Living Legacy", "we", "our", or "us") collects, uses, and protects the personal data of individuals ("you" or "users") who access or use the Living Legacy platform, website, digital applications, or any services provided by Living Legacy (collectively, the "Service").
1.2. By accessing or using the Service, you agree to the collection, use, and disclosure of your personal data as described in this Policy. If you do not agree with the terms of this Policy, please refrain from using the Service.
1.3. This Policy is incorporated into and forms part of the Living Legacy Terms and Conditions ("Terms"), which govern your use of the Service. Any capitalised terms not defined in this Policy shall have the meanings ascribed to them in the Terms.
1.4. The Service is operated and provided within the sovereign territory of Singapore. If you are accessing or using the Service from other jurisdictions, you are responsible for complying with the local laws and regulations applicable to your particular jurisdiction.
1.5. We may revise this Policy from time to time by updating this page. You should revisit this page periodically to ensure that you are aware of any changes, as your continued use of the Service will constitute your acceptance of the revised Policy.
2. DATA COLLECTION AND USAGE
2.1. Living Legacy collects and processes various types of personal data from you in order to provide the Service and for related purposes. The types of personal data we collect may include:
2.1.1. Personal Identifiers:
Such as your name, contact details (e.g., phone number, email address), date of birth, and other identifiers.
2.1.2. User Content:
Any text, images, audio, video, or other content that you upload, submit, or otherwise provide through the Service.
2.1.3. Usage Data:
Information about how you use and interact with the Service, including device information, access logs, and usage patterns.
2.1.4. Location Data:
While we do not currently collect location data, Living Legacy reserves the right to collect and process information about your location when using the Service if needed to aid in furthering or improving the Service.
2.2 We collect and process your personal data for the following purposes:
2.2.1. Creating and Maintaining Digital Replicas: To create and maintain personalised digital replicas or avatars that represent you or your loved ones within the Service.
2.2.2. Providing, Improving, and Customising the Service: To provide, improve, and customise the Service according to your preferences and usage patterns, as well as to develop new features and functionalities.
2.2.3. Creating Digital Companions and Enabling Upskilling/Reskilling: With the end intention of creating digital companions and boosting reskilling and upskilling initiatives as the product evolves.
2.2.4. Communication and Customer Support: To communicate with you about the Service, respond to your inquiries, and provide customer support.
2.2.5. Service Analytics and Security: To analyse and enhance the Service's functionality, performance, and security, as well as to detect and prevent any potential misuse or abuse.
2.2.6. Legal Compliance and Enforcement: To comply with applicable laws, regulations, and legal obligations, as well as to enforce our Terms and Conditions and protect our rights and property.
3. DATA SHARING AND DISCLOSURE
3.1. Living Legacy does not sell, rent, or share your personal data with third parties for their direct marketing purposes without your explicit consent.
3.2. However, we may share your personal data with trusted third-party service providers who assist us in operating, maintaining, and improving the Service. These third-party service providers are obligated to maintain the confidentiality and security of your personal data and are prohibited from using it for any purpose other than the services they are providing to Living Legacy.
3.3. We may also disclose your personal data in the following circumstances:
3.3.1. Legal Compliance:
If required to do so by law or in response to valid requests from public authorities (e.g., court orders, subpoenas, or other legal processes).
3.3.2. Protection of Rights and Safety:
To protect the rights, property, or safety of Living Legacy, our users, or others, including to investigate and prevent any actual or suspected illegal activities or violations of our Terms and Conditions.
3.3.3. Business Transfers:
In the event of a corporate transaction, such as a merger, acquisition, reorganisation, or sale of assets, your personal data may be transferred as part of that transaction. In such cases, we will ensure that the acquiring entity continues to comply with the terms of this Privacy Policy.
3.4. We may also disclose your personal data in the following circumstances:
3.4.1. With Your Consent: We may share your personal data with third parties if we have obtained your explicit consent to do so.
3.5. Living Legacy takes reasonable steps to ensure that third parties who may receive your personal data are obligated to protect and process it in accordance with the principles and requirements of applicable data protection laws and regulations. However, we cannot guarantee the privacy practices of such third parties.
4. DATA SECURITY
4.1. Living Legacy implements reasonable technical and organisational measures to protect the personal data of our users from unauthorised access, alteration, disclosure, or destruction.
4.2. We store user data, including User Content such as images, audio, and videos, in encrypted format on secure servers. Data in transit is also encrypted using industry-standard protocols.
4.3. Additionally, we employ various security measures, including:
4.3.1. Secure access controls and authentication mechanisms
4.3.2. Regular security audits and vulnerability testing
4.3.3. Firewalls and intrusion detection systems
4.4. However, no method of data transmission or storage is completely secure, and Living Legacy cannot guarantee the absolute security of your personal data. While we take all reasonable precautions to protect your data, we cannot be held responsible for any unauthorised access, alteration, disclosure, or destruction of data that may occur through no fault of our own.
4.5. We encourage you to take appropriate measures to protect your personal information, such as maintaining the confidentiality of your login credentials and implementing robust security practices on your devices.
5. DATA RETENTION AND DELETION
5.1. At Living Legacy, we retain your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy's "Data Collection and Usage" section, unless a longer retention period is required or permitted by law.
5.2. The criteria used to determine our retention periods include:
5.2.1. Legal obligations: We may retain certain data to comply with applicable laws, regulations, legal processes, or enforceable governmental requests.
5.2.2. Business operational needs: Data may be retained as long as necessary to provide you with the Service, manage your account, resolve disputes, and enforce our agreements.
5.2.3. User instructions: We may retain data in accordance with your instructions, such as when you request us to keep certain information for a specific purpose.
5.3. Users can request the deletion or removal of their personal data from Living Legacy's systems by submitting an email request to our customer support team at general@livinglegacy.sg. We will respond to all verified deletion requests within 30 days and make reasonable efforts to delete or anonymize your personal data from our active systems.
5.4. However, please note that we may be unable to delete or modify certain data contained in digital replicas or avatars created through the Service, as that data may be intrinsically linked to the core functionality of those features. Additionally, some data may remain in backup or archived records as required by applicable laws or our data retention policies.
5.5. If you have any questions or concerns about our data retention or deletion practices, please contact us at general@livinglegacy.sg.
5.6. We encourage you to regularly review and update your personal information to ensure its accuracy. You have the right to access, correct, or request the deletion of your personal data in accordance with applicable data protection laws.
6. USER RIGHTS AND CHOICES
6.1. Living Legacy respects your rights and provides you with choices regarding your personal data. Depending on the applicable laws and regulations, you may have the following rights:
6.1.1. Access:
You have the right to access the personal data we hold about you and obtain a copy of that data.
6.1.2. Rectification:
If any of the personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected.
6.1.3. Erasure:
In certain circumstances, you have the right to request that we erase your personal data from our systems.
6.1.4. Restriction:
You may have the right to request that we restrict the processing of your personal data in specific situations.
6.1.5. Portability:
Where applicable, you may have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format.
6.1.6. Objection:
You have the right to object to the processing of your personal data in certain circumstances.
6.2. To exercise any of these rights, please submit your request by email to general@livinglegacy.sg with detailed information about your request. We will respond to all verified requests within a reasonable timeframe and in accordance with applicable data protection laws.
6.3. Please note that while we will make reasonable efforts to fulfil your request, there may be instances where we cannot delete or modify certain personal data contained in digital replicas or avatars created through the Service, as that data may be intrinsically linked to the core functionality of those features. Additionally, any text information you provide through the Service may be used as training data for our systems and may not be removable.
6.4. You can update or modify certain personal data directly through the Living Legacy web application or by contacting our customer support team. We encourage you to keep your personal information accurate and up-to-date at all times.
6.5. If you have any questions or concerns about your rights or choices regarding your personal data, please contact us at general@livinglegacy.sg.
7. THIRD-PARTY SERVICE LINKS
7.1. The Living Legacy Service may integrate with or contain links to third-party websites, services, and applications ("Third-Party Services") that are not owned or controlled by Living Legacy. Examples of such Third-Party Services include social media platforms, cloud storage providers, or other tools and technologies that may be incorporated into or accessible through our Service.
7.2. Living Legacy does not have control over the privacy practices, content, or operations of these Third-Party Services. Any personal data you provide or activities you engage in while using these Third-Party Services will be subject to their respective privacy policies and terms of use, not this Privacy Policy.
7.3. We strongly advise you to review the privacy policies and terms of any Third-Party Services before using them or providing any personal data. Living Legacy is not responsible for the privacy practices or the content of such Third-Party Services.
7.4. Certain Third-Party Services may allow you to authenticate or log in using your Living Legacy account credentials. By enabling this integration, you authorise Living Legacy to share certain account information and data with the Third-Party Service as necessary to facilitate the integration.
7.5. The inclusion of a link to a Third-Party Service on the Living Legacy platform does not imply our endorsement of the Third-Party Service or any association with its operators. We reserve the right to modify, disable, or discontinue integration with any Third-Party Services at any time without prior notice.
7.6. If you have any concerns about the privacy practices of Third-Party Services, please contact the respective service providers directly.
8. UPDATES AND CHANGES TO PRIVACY POLICY
8.1. Living Legacy reserves the right to modify or update this Privacy Policy at any time. We will reflect any material changes to our data practices through updates to this Policy.
8.2. If any updates constitute a material change, we will notify you by reasonable means, such as by posting a prominent notice on our website or sending a direct notification to the email address associated with your Living Legacy account.
8.3. Your continued use of the Living Legacy Service after the effective date of any updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree with the terms of the updated Policy, you should discontinue your use of the Service.
8.4. We encourage you to periodically review this Privacy Policy for any changes. The "Last Updated" date at the top of this document indicates when the latest modifications were made.
9. CONTACT INFORMATION
9.1. If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer at:
Email: general@livinglegacy.sg
9.2. We will make reasonable efforts to respond to your inquiries and address your concerns in a timely manner.